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Beware States Offering Unilateral Advance Pricing Agreements for Transfer Pricing

USA - August 26 2020 As state revenue agencies train their auditors in traditional IRC §482 transfer-pricing methodologies or outsource transfer-pricing audits to…

Adam P. Beckerink, C. Terrell Ussing, Matthew S. Mock.

Athletes, Artists, and Audits: IRS Renews Focus on High-Wealth Individuals and Associated Entities

USA - June 23 2020 The IRS has announced its intention to audit wealthy taxpayers and their associated business entities starting in mid-July. This LawFlash alerts…

Michael D. Kummer, Sarah-Jane Morin.

Key US Tax Rules for Foreign Athletes and Entertainers, Law360

USA - September 11 2019 When Canadian women's tennis player Bianca Andreescu defeated Serena Williams in a stunning upset in the 2019 U.S. Open, she probably wasn't thinking…

Jason D. Dimopoulos.

Ninth Circuit Panel Upends Arm’s Length Standard in Cost Sharing

USA - August 6 2018 July 24, 2018, marked a significant, although potentially short-lived, victory for the Internal Revenue Service (IRS), as a panel of the US Court of…

Jenny A. Austin.

Transfer Pricing Audits Under the New Transfer Pricing Examination Process

USA - July 19 2018 Serving as a roadmap for how the Internal Revenue Service intends to conduct transfer pricing examinations, the recently released Transfer Pricing…